Saturday, September 29, 2012

The very best part about getting married in France is the possibility of having two weddings. That means two ceremonies and two parties. Twice the fun and, let me tell you, the French sure know how to party. My French weddings were 20+ years ago and today is the anniversary of one of them. We spaced them perfectly so that we have one in the spring and one in the fall and that means we get two celebrations every year and two sets of presents.

How is that possible, you might ask? Well, you need to know that only one of the weddings is legal in the eyes of the government and that's the ceremony at the mayor's office. That first wedding was quite an adventure for me and it did not begin well. We were living in Courbevoie at the time, my French was very limited and I was undergoing severe culture shock. For some reason that I no longer remember, we decided that I would be the one to go down to the mairie and start the process. It was a catastrophe. There were all sorts of questions to answer and my vocabulary simply wasn't up to the task. But the worst moment was when they asked me about my future father-in-law and his profession. I replied that he was a retired Army officer and they wanted to know his rank at retirement. Easy enough for me to answer because "General" in French is "Général." Their response to this? They laughed at me. From the questions that followed (decorations, service and the like) they didn't believe me.

To be fair, put yourself in their place - here was this very young American woman in jeans with limited French and a terrible accent who was standing there saying that she was going to marry the son of a French général d'armée. The only question I could answer about his service record was that he had the Legion d'honneur which amused them even more. I left the office in tears and went home to call my fiancee to say there was a problem. He called his father straightaway and he called the Army who sent (according to my father-in-law) a colonel down to the mayor's office to provide the requested information. Merci, Papa. Needless to say things went very well after that and we even got a call from the mayor's staff saying that all was in order and if we needed anything further, they were there to help.

The wedding went off without a hitch after that. It was a beautiful spring day. My mother-in-law was ravishingly beautiful in her fur coat and jewels and my father-in-law was the picture of quiet dignity in his very classy grey suit (but not his uniform that he saved for the second wedding which we'll get to in a moment). When I was first told that we were getting married at the mayor's office I had this vision of some stark modern office and a quick efficient little ceremony that would have us in and out in 15 minutes or less. I could not have been more wrong. The room was splendid and the mayor performed the ceremony with solemnity and style. Here are a few photos:

On to the second wedding - the anniversary of which we are celebrating today. The second wedding was held because we are Roman Catholic and a church wedding was (even though it wasn't legal) the "real" one for us and the family. It was also the one with the really big party. It was held at Ste. Odile in Paris and everyone went to town. I had a "Princess Di" dress - white with lace, a full skirt that was huge and held up by hoops, and a long long veil. My father-in-law was in full uniform with all his decorations and the most extraordinary hat (called a képi). The best man was equally splendid in his French Navy uniform. My American grandmother wore her fur coat as did my mother-in-law (hey, it was cold fall day). My brother walked me down the aisle but strangely enough I don't remember a darn thing after that until the moment I walked out of the church into the sun and saw one of the flower children - a three year old French cousin carrying a teddy bear - looking up at me like I was a fairy princess come to life. Only time in my life I've ever felt like one. The rest of the day was a whirlwind of activity. There was a ride on a bateau-mouche on the Seine and a dinner with a three-tier wedding cake, the most amazing meal and dancing at the Cercle national des armées. The entire family was there (French and American), all our friends, and one guest of honor: the old friend and bridge partner of my father-in-law, the Emperor Bao Dai.

It really was a day to remember. I looked for but could not find the official weddings photos though I'm sure they will turn up when we move. But here is one that was taken by my sister-in-law's husband that I like. I'll post the others in the spring when the other anniversary rolls around.

Friday, September 28, 2012

After months of letter writing, multiple blog articles and the tireless efforts of organizations like ACA and AARO, the issues that Americans abroad have with the extra-territorial U.S. legislation, FATCA (Foreign Account Tax Compliance Act), have made it to the mainstream American media.

Sure, some journalists have been nibbling around the edges of the issue with articles about the rising number of Americans renouncing U.S. citizenship and the rising concern over FATCA as we get closer and closer to implementation but there hasn't been much that ties it all together for a general homeland audience.

The article is concise, well-written, factually correct and tells the stories of real people who are impacted by this legislation. What a relief and joy to read the words of a journalist who dug deep enough to get the real story which is not about rich Americans living it up on the Riviera (that's the main theme for other journalists who are too lazy to look farther than the ends of their noses) but about people like Scott Schmith from Sioux City, Iowa. A veteran of the U.S. military, he's worked abroad for 20 years and has a photography business in Switzerland. Or Genette Eysselinck from North Carolina who is married to a Belgian national and has lived in Europe for many years.

These people and many others like me are the collateral damage in this grand scheme to fight tax evasion - the eggs that are being broken in the making of the FATCA omelette. Like Mr. Schmith and Madame Eysselinck (two very courageous Americans abroad who allowed their names to be published in this article), I don't particularly want to give up my U.S. citizenship either. But there are days when after trying so desperately trying to capture the attention of homelanders in the U.S. or to get even the briefest acknowledgement that there might be a wee problem with their plans for world domination out of a U.S. lawmaker, one does have to wonder if cutting those ties (however painful that may be) might not be the only sane solution left.

This quotation from Mike Helmos sums up quite nicely our concern that things, as bad as they are now, could get much much worse. He says, "FBAR and FATCA seem to be tipping points. Americans who reside abroad have a lot of different annoyances and problems that come with citizenship. With FBAR and FATCA, it is like, 'What else have you got for me?'"

Thursday, September 27, 2012

And another good video passed along by a Flophouse reader. It's called "Paris versus New York" by Tony Miotto. It's a comparison of all the stereotypes we think of when we hear the names of these two cities. It was inspired by this blog called Paris versus New York: A Tally of Two Cities by artist Vahram Muratyan.

I really enjoyed it and I wonder (hint hint) if someone would be up for doing one about Versailles versus Seattle?

I am flat on my back these days with the mother of all colds. As I near the end of my chemo, this is not a good place to be since the last thing I want is for Chemo Round 6 to be postponed because I'm sniffling and coughing. So I went to the doctor yesterday and have a truckload of antibiotics and strict instructions to stay home and stay warm.

The younger Frenchling was also sick (she was my Typhoid Mary) so we spent a lot of time together - me on the couch and her in her favorite chair. I read paranormal romance novels and she practiced her Japanese by watching anime and other stuff on the Internet. She came across this video which she shared with me. I found it fascinating. It was filmed in Japan and it shows interviewers stopping "gaijin" (foreigners) in the street and asking them to talk (in Japanese) about their favorite things in Japan. (Yes, Nozaki-san, I know you told me not to use the word "gaijin" in polite company but everyone does use it, right?)

The video is in Japanese, a language I do not speak though I know some essential phrases like how to tell the taxi where I live and how to ask for things in the store. Lucky for me I have a translator at home - the younger Frenchling being a big fan of the Japanese language and culture. She has Japanese language classes at school, a private tutor (the mother of one of her sensei's at her Kendo class) and she spends a lot of time on the Net immersing herself in the language.

I don't think, however, that you need to speak Japanese to appreciate this video. Here are people from all over the world (India, Azerbaijan, France, Ireland, USA and other places) being stopped on the street and asked to spontaneously talk about what they like about Japan. They all seemed reasonably comfortable with the language but some were more proficient than others. Check out the body language as well. And it occurred to me as I watched the Americans that there is something really strange about watching one of your compatriots speaking another language. But what really won my heart, I think, was how good-natured the exchanges were. Everyone seemed to be having a good time - no "pieges" (traps) and no criticism - and when there was laughter it was "laughing with" and not "laughing at." This exercise was not designed to embarrass the foreigners though some of the answers were pretty funny. Enjoy.

Friday, September 21, 2012

It's been a very busy September here at the Flophouse. Not only are we busy with our house project but we have had many visitors this month.

Earlier this month, my mother-in-law came to stay since my spouse was abroad for business and the family agreed that leaving me here by myself was a bad idea. Did I mind? Not a bit. My French mother-in-law is one of the smartest women I know and our conversations are always interesting. Over 80 years old this woman was young when France was invaded during World War II. Later she married a French army officer and moved to Algeria where my spouse and his sister were born. They came back to France in 1962 and lived in various parts of the Hexagone including Versailles. On Sunday we went to mass together at the chapel at the convent of les Sœurs Servantes du Sacré Cœur de Jésus and as we walked she pointed out their old house and the school my sister-in-law attended both of which are very close to our new house in Porchefontaine.

My mother-in-law hails from the Limousin, a sparsely populated region in France that has a very long history. The city closest to the town where she was born and raised is Limoges which was founded in the Roman era (around 10 B.C.) and is best known today for its porcelain.

On one of my very first trips to France my future husband took me out to that region to spend Christmas with his grandmother (my mother-in-law's mother) in Saint Junien. So my first impressions of France were not about Paris but about what they call La France Profonde (Deep France). I remember our trip vividly for two reasons: the grilling that I experienced on the first day by Mémé (she would have made a fine "Inquisiteur" in the Middle Ages) and the quality of the dinner. We had goose from the market and chestnuts. Delicious.

Like her mother, my mother-in-law is one of the best cooks around. What she can do with some inexpensive cuts of meat and a few vegetables is nothing short of miraculous. She is also a great believer in using "les restes" (leftovers). There was some rice left in the fridge and she made a lovely gâteau de riz which I ate for breakfast several days running. To those who argue that copious amounts of money must be spent for the highest quality ingredients in order to eat well, that simply isn't true. What one really needs to eat well and frugally is time. The stew for lunch goes on in mid-morning and preparations for the dinner meal begin not long after lunch. I ate so well during Maman's time here that I gained 2 kilos (about 4 pounds) - something that delighted my doctors at the clinic.

My parents arrived from Seattle via Reyjavik and Amsterdam about a week after my mother-in-law left. Both my parents were born on the U.S. West Coast in the states of Washington and California. They are the perfect guests from out of town. Both are very well-travelled and you could probably drop them just about anywhere in the world and they would make do just fine. My mother who was born in Seattle (which makes me a very rare beast - a second-generation Seattleite) spent her summers working at her grandparent's farm near the village of Naches(population 700) which is close to Yakima in Eastern Washington. Just call this l'Amerique profonde (Deep America). As a result she has a number of skills that are rather uncommon today. In addition to being a fine writer and photographer, she knows how to milk a cow, churn butter, sew, and bake delicious bread and pies (and the pie crust is always hand-made). Of the four skills I've listed here (and I'm sure there are more I don't know about) I've only inherited two out of four and I think the Frenchlings only have one (they love to bake).

They went down to both the local market at Porchefontaine (about 10 minutes away from our apartment) and the main market in the center of Versailles and came back each time with butter and cheese, lamb, and fresh fruits and vegetables. To say that I ate well during their stay would be an understatement. My mother made an open-faced pie with hand-made crust and four kinds of fruit that I am still eating for breakfast. I got on the scale this morning and I've put on roughly another 2 kilos. And it was all good food too - like my French family, my American family doesn't do "Coca-Cola and chips" though I used to sneak these things into the house when I was a teenager. And when my mom found out (as moms always do) there was hell to pay - it was seized as contraband and disposed of forthwith.

So thus far the month of September has been a kind one. I had visits from people I love and don't get to see nearly as often as I would like. There was intellectual stimulation, good conversation and a steady stream of fine food that I didn't have to cook. I am also about 4 kilos heavier - a good thing since, like all the folks in my family with Norwegian blood, I tend to be on the tall and thin side: 173 centimeters (5 feet 8 inches) and about 54 kilos (119 pounds). Not the best place to start when you are facing 5 rounds of pretty aggressive chemotherapy.

Fortunately for me, "Mom" and "Maman" have made it their mission to correct this and today this particular problem is well on its way to being resolved. Between you and me, I feel a lot better and stronger. Which for me just proves beyond a shadow of a doubt Michael Pollan's food rule, "Don’t eat anything that your great-grandmother wouldn’t recognize as food." Only way to do better is to actually have grandma/grandmère come by and cook that "real food" for you.

Wednesday, September 19, 2012

Not long ago we looked at different ways that countries tax their diasporas. We began the series by asking some very basic questions about territorial and extra-territorial taxation and then moved on to tax systems that specifically target a country's population living outside of national borders: citizenship-based taxation and exit taxes. But there was one we missed and it's an important one - estate/inheritance tax.

A country may or may not (usually not) practice territorial taxation on investments and earned income but may still seek to extract some revenue from worldwide assets when an individual performs the ultimate act of expatriation - death.

It's worth asking the question of why inheritance is taxed in the first place since we can presume that during the lifetime of the person in question he/she already paid taxes (capital gains, income tax and so one) on that money when it was being earned. One argument in favor of it is that it is good social policy - it generates revenue for the state, breaks up concentrations of wealth, promotes social equality and discourages the creation of an "idle class" (those infamous "rentiers"). As Andrew Carnegie put it: "The parent who leaves his son enormous wealth generally deadens the talents and energies of the son, and leads him to lead a less useful and less worthy life than he otherwise would." Bill Gates concurs and has said that he not only supports the estate tax but he plans on leaving 95% of his fortune to charity as opposed to his children. “Once they graduate from college, then they’re largely on their own."

Those arguments are countered by those who say that it doesn't generate significant revenue, is a drag on economic growth, is harmful to small businesses and farms which must be broken up to pay taxes, and encourages a "Die broke" mentality.

Into this debate allow me to add another layer of complexity. Assuming that most states have some form of an inheritance tax, when a person with assets in multiple countries dies, which government gets a cut? The country of citizenship or the country of residency? Or both? This is important to know if, for example, you are a bi-national couple with dual citizen children - a family that lives at the intersection of two or more sets of national laws.

Please bear in mind as we discuss this that I am not a tax professional and do not play one on TV so double-check my information and feel free to correct me if you find errors.

France: If you are a resident of France (French citizen or not) your worldwide estate is subject to French tax. As Service-Public says, "Si le défunt était domicilié en France, vous êtes soumis aux droits de succession sur tous les biens reçus, qu'ils soient situés en France ou à l'étranger." (If the deceased was resident in France, then you [the heir] are subject to inheritance tax on all the assets received in France and abroad.) However, that may be mitigated by tax conventions signed between nations so it is best to check with an international tax lawyer in your particular case. There is one that covers France/US estate taxes that I found on the U.S. Embassy website.

United States: So what happens if you are a French citizen living in the U.S.? Just like the worldwide tax on income, the U.S. can tax you on your worldwide "patrimoine" if you are on U.S. soil when you pass on. This applies if you are a dual U.S./French citizen, a resident alien or in some cases, a non-resident alien. An example of the last would be a Canadian who resides in Canada but has a vacation home worth more than 60,000 USD in the U.S. Deloitte has an excellent guide to how it works here.

As for Americans citizens living abroad and U.S. estate taxes, yes, there are tax returns to file and, depending on the value of the estate, taxes to pay. Be aware that those tax conventions may be no help at all. This site says: "In these treaties, the United States also reserves the right to tax the estates of its citizens as though the treaty was not in effect at all. Under the terms of its treaty with France, the United States may tax French property owned by U.S. citizens, thus creating the potential of a double tax on the bequest. "

There is also the matter of an American whose spouse is not a U.S. citizen. In the case of a bi-national couple where one is a U.S. citizen and the other is not, this KPMG article says that this has important implications: "The most important estate tax deduction is the marital deduction, which generally permits all transfers of property to the decedent’s spouse to be excluded from taxation, but only if the spouse is a U.S. citizen. Generally, no marital deduction is allowable for property passing outright to a spouse who is not a U.S. citizen."

Are the U.S. and France outliers when it comes to complex estate/inheritance taxes on worldwide assets? Not at all. For an overview of the rules of 27 different countries around the globe, have a look at the superb Ernst and Young International Estate and Inheritance Tax Guide 2012 which is a marvelous resource for those of you who are (like me) complete novices when it comes to international estate planning.

When it comes to cross-border inheritance the sheer number of intersecting national laws and tax treaties make it nearly impossible for the average human to understand all the implications and consequences. Plus these things are not static - laws change, new treaties are signed, capital (human and financial) moves across borders and people keep doing what people generally do: get born, get married, work, have children and pass away. It's a little like a diabolical game of musical chairs where the music stops forever and for all time for one individual (the deceased) and the distribution of his assets depends both on where he lands on the floor and in what seats his heirs find themselves at that moment.

My conclusion? If you are a global migrant or part of a family whose members or assets spans countries or continents, find yourself a competent professional and get this sorted out sooner rather than later.

Monday, September 17, 2012

Broadly defined, citizenship is membership in a political community. Like any club it has benefits and it has duties and responsibilities. But citizenship is perceived to be something much more than just a simple contact between an individual and a state - this is not supposed to be like signing up with Club Med. With citizenship some of the membership rules are explicit (defined by law) but many more are implicit (an understanding or an unwritten social contract). A citizen can be fully compliant with the rules and yet fall afoul of the social contract and be vilified or shunned by the other members.

Attempts to reduce citizenship to a simple cost/benefit analysis or to tie it to monetary terms is almost always regarded with disdain, if not downright hostility. Most people would agree that this connection is not something that should be bought or sold or traded (but it can be inherited or earned through service). To be an American or a Frenchman or a Japanese is supposed to be something a bit more than just a set of rights and a list of duties. What that "something" is can be hotly debated but it seems to come down to a kind of emotional attachment plus a willingness to sacrifice on behalf of the nation. It is a status fraught with meaning.

So a suggestion that we think of citizenship as just another membership in a club where each individual does a personal cost/benefit analysis of present and future benefits and then swaps memberships at will according to his/her interests tends to arouse very angry, very emotional, responses. Most people agree that citizenship is not a membership to be traded in for something better for purely financial reasons. Those who are perceived as trying to do just that (Eduardo Saverin and Bernard Arnault) are considered to be the worst sort of traitorous villains.

And yet the nation-states involved (and their citizens) seem entirely comfortable with the idea of offering very interesting incentives to draw rich and talented residents to their shores. Remember that every immigrant is someone else's emigrant and one state's gain is another's loss. To those who argue that citizenship has no price (or should not be priced), one doesn't have to look far to find ways that states themselves put a sticker price on citizenship/residency and invite migrants to meet it for mutual advantage and profit. The U.S. and France are not exceptions to this. Don't believe me? My French spouse didn't so I went and looked and this is what I found:

Carte résident - contribution économique exceptionnelle: For the modest sum of 10 million Euros and/or a commitment to create (or save) 50 jobs, an investor will receive a French residency permit good for 10 years. As a bonus, the immigrant investor is relieved of two requirements: the "Visite medicale" and the "Contrat d'Accueil et d'Intégration." Citizenship in this case is just a short step away since someone who is deemed to have "rendu (ou peut rendre) des services importants à la France" can apply for French citizenship after a mere two years of residency.

Hard to see this as much more than a purely commercial transaction and the French government website is not coy about the deal:

EB-5 Immigrant Investor: This has been described as a "Visa for Dollars" or "Swapping boat people for yacht people" program. If you ignore the citizenship-based taxation part of US tax policy this is a steal compared to France. For the very reasonable sum of 1 million U.S. dollars (500,000 in a poverty-stricken area) and the creation of a measly 10 jobs, an investor get an immigrant visa and a conditional Green Card. Once the probation period is over he gets a regular Green Card and a path to U.S. citizenship after 5 years. Other advantages are being able to the family over and the children can work or go to a U.S. school and benefit from in-state tuition rates. Investors must reside in the U.S. but they only have to be physically present on U.S. soil for 180 days out of the year. The only catch is that they have the same reporting and tax obligations as other Green Card holders: they must report and pay taxes on their worldwide income and assets. Again, like the French program, this is a purely commercial arrangement - a genuine quid pro quo.

So for 10 million euros you can be French (EU) and for 500,000 USD you can be American.

A hell of a deal, don't you think?

A modest suggestion to the citizens of the two nations mentioned above: if you don't want individuals shopping around for the best citizenship "deal" and you wish to vilify those who do, your moral posturing would be much more credible if you weren't the ones putting it up for sale in the first place.

Saturday, September 15, 2012

It's September, the children are back in school and their parents are back to work (some of them anyway) and it's time for the other main event of La Rentreé, La Fête de l’Humanité.

This is a huge festival held in the Paris region every year and it's quite the party with music, debates, expositions and other "spectacles." As always people are having a rip roaring good time. The concert program alone is pretty impressive with just about every kind of music you can imagine. If I could go, however, I would attend the debates. What I would give to be there for the discussion on topics like:Qu’est devenu le Printemps arabe? (What Has the Arab Spring Become?), Vivons-nous en démocratie? (Do We Live in a Democracy?) and the not-to-be-missed Quand l’Amérique s’éveillera (When America Awakes).

The last is perhaps more a hope than a reality. I was raised by American hippies, people who dreamed of such an awakening, but it didn't happen 50 years ago and I'm not sure things are looking up as we enter the 21st century. As I contemplate voting in the 2012 U.S. elections I find myself singing:

Well I don't know why I came here tonight

I got the feeling that something ain't right

I'm so scared in case I'll fall off my chair

And I'm wondering how I'll get down the stairs

Clowns to the left of me, jokers to the right, here I am

Stuck in the middle with you

La Fête de l’Humanité has been around since 1930. At that time the French government was putting Communists in prison and the party fought back in various ways one of which was this festival held to bring people together and to finance their journal l’Humanité which is still alive and well today. The festival has grown up over the years - it's a lot more diverse and will welcome hundreds of thousands of people this weekend to the festivities at la Courneuve en Seine-Saint-Denis.

For this 77th manifestation of the Fête, the director of l'Humanité, Patrick Le Hyaric, gleefully wrote:

"Nous avions clamé l'an passé, sur des affiches, des tee-shirts, sur la grande scène, que la Fête de l'Humanité 2011 devrait être la dernière fête avec Sarkozy pour président. C'est le cas aujourd'hui!"
(We said last year, on posters, t-shirts and on the main stage, that the 2011 Fête de l'Humanité would be the last festival with Sarkozy as president. And that is the case today!)

May I say how delighted I am that somebody is getting his heart's desire this election year.

The American Diaspora is relatively small: 6-7 million Culex Pipiens versus 300 million homelanders. That is not our only disadvantage - Americans abroad are a very diverse population scattered among the 190+ countries of the world and for the most part we don't ask much of the homeland or publicize our presence outside the U.S. That's changing as a result of some burning issues that are bringing us all together. Communicating how we feel about them and getting heard, however, has been a sisyphean task. Our letters go unanswered by lawmakers and our fellow citizens toggle between hostility and indifference when we try to talk about it. It's almost impossible to understand the magnitude of the problems and how the situation between Americans abroad and the homeland has degraded until you see the list (the very long list) of grievances. It's not just about FATCA, my friends.

We were sorely in need of a good "synthèse" - something that brought together the issues, our frustration and feelings, and what we want to have happen next. Earlier this year a group of American citizens and organization in Switzerland held a series of Town Hall Meetings in five Swiss cities. The report on The Concerns of Overseas Americans that came out of these gatherings is exactly what we needed. I read it over carefully and can attest personally to the fact that the major issues they cite are not at all confined to Americans in Switzerland or Europe, but are being experienced by Americans abroad all over the world wherever they live. I fully support their recommendations which I find both reasonable and relatively modest. We are hardly asking for the moon here, folks.

This report has already been sent to every member of the U.S. Congress but let's take it one step further. I strongly encourage everyone to pass it along to other Americans abroad, to friends and family back in the U.S., to every candidate running for office in your U.S. voting district, and to every national and hometown newspaper.

If enough of us buzz loudly enough perhaps we can keep the homeland humans awake long enough to hear us out. And if that doesn't work, let's draw some blood and get them scratching...

Tuesday, September 11, 2012

Those pesky campaign promises. During the 2012 French presidential elections François Hollande announced his intention to tax people earning over 1 million Euros a year at 75%. Now that he's president, the pressure is on and his supporters want him to keep his word.

Hard times here. Unemployment is up (9.7%) and at the beginning of this month the number of unemployed reached 3 million - something that Rue89 is calling "un électrochoc national." It's not likely to get better soon and the idea that the rich should pay more taxes is pretty popular politically.

But now pressure is coming from another direction. Bernard Arnault, the CEO of LVMH, has made a request for Belgian citizenship. Mr. Arnault says that this move is not a result of tax policy and that he simply wants dual citizenship to take advantage of business opportunities. He already has a home in Bruxelles though he remains, for the moment, a French resident for tax purposes. I believe him. It's not really about citizenship since France does not have a citizenship-based taxation system. All Mr. Arnault has to do (provided he pays the applicable exit taxes) is to change his residence and he can do that as a French or a Belgian or a Martian. He's an EU citizen and has the right to move to whatever country here will have him.

Nevertheless people are asking themselves if he will be the first of a wave of emigration out of France toward more fiscally interesting locales and that is making everyone a bit nervous. What use is a 75% tax on the rich if the 2-3000 people it applies to pack up and leave? Sure they will pay something on their way out but the state will lose all that potential revenue for the future. 75% of nothing is still zero last time I looked.

Quite a conundrum that the French government is taking very seriously. As this article in Le Parisien puts it: "Dans ce contexte, tout recul sur la taxation des plus riches serait inacceptable aux yeux de l’opinion publique. Mais comment éviter un impôt « confiscatoire » et risquer un exil des talents?" (In this context, backsliding on taxing the richest would be unacceptable in the eyes of public opinion. But how to avoid "confiscatory" taxes and the risk of losing talent?)

That is the question of the hour and one that is being asked in many countries all over the world who are struggling with troubled economies and high deficits. The details of Hollande's plan will be only be known at the end of this month. Can Hollande and his government find a compromise that satisfies everyone? A suivre....

Monday, September 10, 2012

La rentrée has a special meaning for this Franco-American family. Every year around this time my parents come over from the Pacific Northwest to Europe. Their trip has two purposes: business because my father always attends the International Broadcasting Convention in Amsterdam in early September and a family visit to see us in the Paris region. It will be twice as nice to see them this year since I wasn't able to go to Seattle this summer and I missed my sister's birthday party in Portland, Oregon. Here is a family portrait from the event (taken by a family friend who is one hell of a photographer) which will give you some idea of the fun I missed.

A few weeks back I posted about Letters of Note and made the comment that email is the lesser medium. Well, when you living a few thousand miles away from the family, email and social media do make it much easier to keep in touch. Also, all emails are not equal. My mother's emails in particular are always welcome in my inbox and not just because she's my mom. She is an excellent writer (and also a fine photographer) and her missives are always entertaining. As they have trekked from the U.S. West Coast to Northern Europe via Iceland, my mother has been sending a steady stream of commentary about the trip and these are emails worth keeping. Here is the latest (posted with her permission):

It's perfect today, canal-side room, perfect fall weather: sunny but just a little crisp, the kind of weather when you wonder if you should put on a sweater when you go out but decide not to and its perfect. B is off to his meetings at the convention and I am getting ready to go out but now just sitting in my room in the sun watching the canal boats go by.I must say if you are traveling to Europe and probably a few other places, Icelandic Air's flight from Seattle seems to work well - leaves at 4:30pm putting you at the airport at a civilized 2:30. They fly 757's, a perfectly nice airplane. First nice thing is that it left on time with little fuss. They tuck you in with a pillow and blanket and, after turning off the seat-belt sign, they start drinks, warm nuts and a very acceptable little snack, followed by a shrimp salad progressing to a choice of three dinner items - you know: beef, fish, and in this case duck breast. I can speak for two out of the three - quite good...

After dinner the disciplined types who avoid the entertainment can get what passes for a "good" night's sleep. Seven hours later (more or less) you reach the coast of Iceland, and off in the distance, the terminal. It looks like a maintenance building in Alaska but closer up its a lovely modern building -light, airy, not crowded and very clean. Not much for visual clutter, I enjoyed the lack of bad public art. Another good thing, you go thru passport control here rather than the much more crowded Amsterdam airport. And, they appeared to be less than intensely interested in who I was and totally uninterested in where I was going and or for how long. Slipped the passport thru the window, guy looks up, stamps it and off I go. Waiting room was comfortable and those Icelanders don't cater to the dim. When they are ready to board, someone shows up, we line up and get on the plane. Announcement? Well no. Why bother since its a small space and, for the couple who were going to sit until there was a official boarding call, they may still be there.Two more hours and we are in Amsterdam, landing just after noon, so if you slept you could be somewhat acclimatised. I am not one of those people.

Decided to try the train rather than a cab. Note here, European train stations don't accept the chipless American credit cards or cash in the ticket machines. So we shlepped upstairs and found the ticket desk, after asking for directions; the nice guy, in English, pointed out that it was behind us and wasn't rude enough to mention that the sign is huge (OK we were jet-lagged) . Train works really well - it's in the airport basement, ramp accommodates rolling luggage and it's very fast, no stops between the airport and the central Amsterdam train station, and it's cheap. Cabs, especially during rush hour, are much slower and amazingly expensive even for those of us from Seattle - land of expensive cabs.

Additional notes - And Icelandic air is among the cheapest ways to get to Europe. Speaking of historic over-grazing, you know since 1200, nothing in Iceland appears to be more than knee high. Spending a couple of days on the way back and on our way to the airport B asks if I packed my swim suit; huh- Iceland, fall? He packed his but forgot to mention it- you know, thermal pools. Considering it a shopping opportunity, yet another piece of swim-wear to add to my collection of purchases associated with bad packing. My distaste for packing is only matched by my distaste for unpacking - the entire process is a big bore. No excuses for me the child of a master packer. My mother savored the packing experience like a fine wine - she would start weeks before a big trip slowing adding pieces to her suitcases, each piece ironed (yes, including underwear) and wrapped in tissue paper.

My mother once wanted my father to stop and purchase a new pair of socks for me after I was run over by a truck that avoided everything but my foot. My father, a quick-witted sort of guy, remarked as we were headed to the hospital that the tire print on my sock would be helpful to the xray technician. Of course this devotion to packing perfection almost killed the family cat. Mother's suitcase was colonized for a sleeping venue by the cat and mother closed the suitcase and walked off only noticing a muffled screaming later. How much later? She was never really owned up to how much later - cat survived, as cats generally do.

If we just look at the top ten, we see companies from the U.S. but also from China, India and Japan.

For those who argue that European companies are stymied by over-regulation, heavy taxation and the "socialist" tendencies of their governments, please note that a UK company comes in 10th on the list and a French company, Pernod Ricard, is 15th.

In fact, there are quite a few French companies on the list. Le Point has an article here which talks about "les entreprises tricolores" that made the cut: Danone (ahead of Apple), Essilor, L'Oreal and others.

I was personally very pleased to see that one of my former employers, Dassault Systèmes, is on the list. They deserve it - it's not only a great company to work for but it's filled with people who are wicked smart and very VERY creative. I saw things when I worked for them that just blew my mind.

Every so often when people find out that I hail from Seattle, I get asked, "Since you're an IT person, why didn't you stay there and work for Microsoft?"

Well, put yourself in my place. Sure I could have stayed in Seattle but where was the fun in that? I was born there and the city holds few mysteries for me. There was also no guarantee that Microsoft or any of the other companies based there would have hired me. By leaving I got the chance to work for what Forbes has recognized as a highly innovative international company, to live in two of the world's most beautiful cities (Paris and Tokyo), and to travel all over the world (China, Germany, Korea, India and many other places.)

When Americans travel abroad, they are often surprised at how well other countries do the things we used to think America does best. In fact, one reason so many American businesses still lead the world is because they benchmark the competition and emulate best practices. But suggest to an American politician that we should try to learn from other countries, and he will look at you like you are from Mars. It is somehow unpatriotic even to raise such comparisons.

I'd say the situation is even worse than that. Not only do those of us who abroad get laughed at when we make even the most mild suggestions about how practices learned elsewhere might be quite helpful in an American context, but we also get treated like Benedict Arnold's - tax evaders and potential terrorists until proven otherwise.

Forget "brain drain." These days it's about "brain circulation." The U.S. must recognize that not only does it benefit enormously when its people go abroad but, in a globalized world, its got competition as a pole of attraction. In the 21st century, some effort is required to convince migrants to move there and stay - an effort that is not helped by American tax policy. It also needs to start seeing its diaspora as an asset, a pool of people who do a lot of quiet good for America wherever they live. I've yet to meet a single American who has given one thought about ways to get back those Americans who went abroad in the first place. Other countries recognized long ago that their expatriates are rich in experience that cannot be taught at a hometown university or learned at corporate HQ in Topeka, Kansas. They have positive (not punitive) policies to encourage their citizens to go abroad and come back.

And that is one set of "best practices" that the U.S. should definitely take from the wider world.

Saturday, September 8, 2012

Yesterday morning bright and early I was in a taxi being driven to my hospital in St. Cloud. My driver is a Frenchman of Algerian origin and over the past month or so we have had many interesting conversations on a wide variety of topics. This trip was no different and the topic of the day was emigration. He told me his story and I told him mine. He came to France when he was two years old and just recently became a French citizen. As I was explaining what brought me to France he started to laugh. He said that he had relatives and friends who dream of moving to New York or California and he thought it was a bit ironic that in his cab he had an American who gave all that up to go elsewhere. And he conceded that he had never really asked himself, "À quoi rêvent les américains?" (What do Americans dream of?)

Singapore, I replied with no hesitation. Also Paris, London, Beijing, Bangalore, Buenos Aires, and hundreds of other places. Just like Algerians, I said, Americans feel a "pull" to go abroad, see the world and take advantage of all that globalization has to offer. Right now, I told him, there are Americans in the United States who dream deep dreams of coming to the city he already calls home (Paris).

Eva Hoffman once wrote:

Multivalence is no more than a condition of contemporary awareness, and no more than the contemporary world demands. The weight of the world used to be vertical: it used to come from the past, or from the hierarchy of heaven and earth and hell; now it's horizontal, made up of the endless multiplicity of events going on at once and pressing at each moment on our minds and our living rooms. Dislocation is the norm rather than the aberration in our time, but even in the unlikely event that we spend an entire lifetime in one place, the fabulous diverseness with which we live reminds us constantly that we are no longer the norm or the center, that there is no one geographic center pulling the world together and glowing with the allure of the real thing...

"There is no center" - what an extraordinary idea. Just poles of attraction that change from one era to another and, in our time, they are multiplying rapidly. The lure of the unknown, dreams of distant shores and the desire to pack up and go somewhere, anywhere, other then the world into which one has accidentally been born is universal. I contend that the "people who move around," regardless of their country of origin, socio-economic status, skills, and talents, are fundamentally very much alike.

And that is why sometimes it is easier for two immigrants, an American and an Algerian, to speak freely, swap stories and come to a common understanding than it is for either of us to talk to our compatriots in the countries we left behind.

Friday, September 7, 2012

There is a wonderful post up on the blog MonVersailles, one of my personal favorites and the place I go regularly to get information about what's going on around town. It's called 12 idées reçues sur Versailles et les Versaillais and it is an eye-opener.

Most people's view of this city is filtered through Le château de Versailles. Ok, the castle is impressive. I personally think it's a bit gaudy but I'll admit that my heart leaps just a little when I come to the end of my street and I see it in all its splendor.

But where did people get the idea that the entire population of Versailles lives there? Sure, the castle is big but I just don't think you could fit 88,500 people in it. Thankfully, there are plenty of houses and apartments here that range from the very modest to the quite grand and expensive.

From the MonVersailles post, here a few things you probably didn't know about the city. I won't translate the entire post (take a few minutes and give your French a workout), just a few of the misconceptions with some commentary by me (someone who indeed "est venue d'ailleurs.")

Versailles is an Old City: "Old" is relative. For an American like me from the city of Seattle, Versailles's age is impressive. This city has been around for 350 years. The city of Seattle is nothing compared to that since Seattle was founded in the middle of the 19th century which makes it a little over 150 years old. But if you look at other cities in France like Tours which has been around since the 12th century (and it should be noted that the Romans were there even earlier) then, yes, Versailles is relatively young.

Versailles is Far From Paris! Nonsense. 20 minutes by train. I do it all the time. On a good day you can get to Paris even faster by car.

Versailles is a Very Catholic City: Not any more than the rest of France and, as MonVersailles notes, other religions have a presence here: a synagogue, a mosque, and several Protestant churches.

With the Castle the City Must be Rich: Wrong. The city only gets money from one parking lot adjacent to the castle and certain taxes on local merchants. The castle doesn't belong to the city and so is not a direct source of revenue.

There Are Only Rich People in Versailles: Nope, 7% of the population is officially poor and most of the rest are middle-class. Just walk into any local store or go the Sunday market and you won't see many people wearing Gucci shoes or driving around in fancy cars. I doubt even the rich would do that - this is not a place where people flaunt their socio-economic status with ostentatious displays of wealth.

There is No Public (Subsidized) Housing in Versailles: Hah! 16% and you can see some photos here. Take a tour around the city and, yes, you will see HLM's.

The Front National Score Must Be Very High in Versailles: The Front National is the far-right party here in France. Versailles is pretty conservative and some of the FN ideas are popular here. It is the only city in France I've lived in where I saw a "Right to Life" (anti-abortion) poster on a main street a few years ago.

That said, something that is worth mentioning here is that my family in California who are very conservative traditional Roman Catholics, consider Versailles to be something of a mecca for the Latin Mass (the Tridentine Rite). I don't want to make a direct association here between the Far Right and Roman Catholics who follow this tradition but MonVersailles does mention the "intégristes" in his post under FN. As a proud owner of a 1962 Latin/English Roman Catholic Daily Missal who is most definitely not a member of this far-right party AND who is an immigrant herself, I'd be very cautious about putting "intégristes catholiques" and the Front National in the same paragraph. If you did a Venn diagram you would probably see some overlap but perhaps not as much as you might think. In any case, I've decided to suspend judgement on this until I actually meet some of these people in these congregations.

Because, after all, just as people have some very serious misconceptions about Versailles, it is worth considering that others have their own "idées reçues" about those who prefer to start their Mass with the words: In nomine Patris, et Filii, et Spiritus Sancti. Amen.

Thursday, September 6, 2012

U.S. citizens and Green Card holders living abroad are waking up to the fact that their status and connections to the "Land of the Free" brings with it certain obligations. If you've ever read The Moon is a Harsh Mistress, one of the great science-fiction classics by Robert Heinlein, you'll be familiar with the acronym "TANSTAAFL" which stands for "There ain't no such thing as a free lunch."

Citizenship is never a "free lunch." All countries require certain things of their citizens and where there are rights, there are also duties and responsibilities. American citizenship is turning to be a very expensive lunch indeed (a four course meal with wine AND cheese AND dessert) because the United States practices something that is often called "citizenship-based taxation." That term is a bit misleading and should probably be renamed "worldwide taxation" because its scope includes people who are not citizens of the United States of America: U.S. residents and immigrants like Green Card holders living in the U.S. or abroad. Very briefly what the U.S. tax system requires is that all U.S. persons (wherever they live) report their personal financial information to the U.S. government, file tax returns and pay U.S. taxes on income or investments earned outside of the U.S. every single year. No other country in the world besides Eritrea does this and it brings new meaning to the old term, "American Exceptionalism."

Most homeland Americans are blissfully unaware of these requirements which is probably normal since they have absolutely no impact on them. What is more disturbing is that until very recently most U.S. Persons (American citizens abroad, Green Card holders and U.S. residents) were also completely in the dark. Overseas Exile has an excellent post about "Expat Alice." This is a very typical story and I know people here in similar situations. Even with the news reports I am still meeting people in Paris like the two American au pairs I encountered a few months ago who have been here for a couple of years working for French families. They went sheet white when I explained it to them. Yes, both should have been filing tax returns and FBAR's since they earned a yearly salary that was over the filing threshold and their parents had set them up with bank accounts here with sufficient money to rent studios and pay their tuition for French classes. Even I, someone is more or less clued in, made my own filing error. It had not occurred to me that my daughter who is a U.S. citizen, should have reported her own bank account in Canada. I had to check but it was indeed over the reporting limit because we set her up (like the parents of the au pairs) with enough money to pay her tuition and living expenses. I had to search our bank records from last year, convert the amounts from Euros to U.S. dollars, and then send all that information to my daughter so she could fill out her own FBAR thus adding yet one more piece of paper that the U.S. Treasury must process in 2012.

So, as you can see, this matter is of more than academic interest to me and it is a topic that I write about often. Am I angry about it? Absolutely. Here I am working on a tax return with my accountant that is so thick I could use it to line my cat box even though not one dime of my income or my investments came from or was earned in the U.S. I have an extension to file late but I still had to pay a few thousand dollars to the IRS earlier this year and now I'm paying for someone to help me navigate the bloated U.S. tax code so I can get the paperwork done. That's pretty expensive cat litter, mes amis. And just for information I am strictly middle-income and have a career as an IT manager which pays decent money but does not, and never will, put me in the millionaire category.

A few months ago I sent out my FBAR which has all my private banking information on it: my U.S. Social Security number, bank account numbers and balances right down to my daughter's savings account with all of a few hundred Euros in it and the checking account that I share with my French husband.

Yes, homelanders, I pay U.S. taxes though I have not lived in the U.S. for years. But apparently many of you don't. On top of all of the above, and to really add insult to injury, was some news I had from a family member who lives in the U.S. and has about the same income. He did his U.S. taxes and was pleasantly surprised to discover that not only is he not paying a dime in Federal income taxes, he gets a refund* of around 4000 USD. Imagine my surprise to discover that he is not alone. According to this Huffington Post article around 46% of homeland Americans didn't pay any Federal income taxes in 2011.

How interesting.

So let me see if I have this straight: someone who lives in the US and has about the same income as me and who benefits from all the government goodies like national parks, Social Security, interstate highways, schools and so on can get away with not paying a dime even for the troops whereas someone like me who lives abroad and uses none of the benefits homeland citizens take for granted ends up with a hefty bill.

I understand that life is not necessarily fair and I am not someone who is against the idea of contributing to the well-being of my country of citizenship. I am also aware that the reason many of these homeland Americans do not pay is because they are too damned poor to do so. You have no idea how much I hate that and how ashamed it makes me to have to admit to it.

But at some point over the past 10 years homelanders ordered themselves up a four course meal at a fancy restaurant and put the bill on a Chinese credit card. In retrospect this wasn't such a hot idea but at the time it was politically very popular to order up a filet mignon for some and to order a bottle of wine for those nice folks at the table on the other side of the restaurant who turned out to be non-drinkers and sent it back. But it's a done deal and arguing over bad past decisions is a fruitless pastime. In fact the national debate in this issue would be vastly improved if every American just accepted that everyone has some responsibility for how things shook out and that the most important thing now is to do the Next Right Thing.

To that end Americans abroad should be given a seat at the national table. We may all be reduced to eating at Mickey D's but I'm cool with that. Representative Carolyn B. Maloney of New York has put forward a very modest proposal for a commission that would start a dialogue between us. It would cost around 3 million dollars a year, a mere drop in the bucket compared to the overall federal budget - though I suppose if we asked a U.S. military contractor to cater it, it might cost quite a bit more than that. The ACA and AARO are ready with some well researched material about how citizenship-based taxation and other homeland legislation effects us and does no good whatsoever for the homeland.

But don't you dare walk out of that restaurant and stiff us for the bill while mouthing platitudes about duty and responsibility and how we are all in this together. Clearly that is not the case and one of these days if that doesn't change, we may be the ones walking and leaving you to do the dishes.

*In my original post I called the money my friend got back from the Federal government a "refund" and a reader asked for clarification. To be precise, it was not a refund of taxes paid but rather a subsidy based on that person's deductions for children and mortgage interest. It wasn't much of one but it still represented a kind of social assistance - a bit like an indirect "les allocations familiales" in France.

Wednesday, September 5, 2012

When people in a country without a national healthcare system talk about "access to healthcare" they are usually talking about making sure people have the monetary means to get medical care. It's a debate about money - affordability, access to medical insurance, and how the care is to be paid for (through private insurance or through a government program).

In a country like France that has a national healthcare system (one of, if not THE, best in the world) "access to healthcare" means something different. The care is there, the system to pay for it is in place but the problem is more one of how to get the people to the healthcare (or to bring the healthcare to the people).

While I was waiting around in the hospital I was very startled to read in a magazine that around 40% of French women between the ages of 50 and 74 do not get regular mammograms to screen for breast cancer. This high rate is in spite of campaigns that have been held yearly since 2004 to get the word out and encourage women to come in for testing. Breast cancer is one of the top causes of female mortality in France and mammograms are essential for women in this age range. And, yet, in 2011 only 52.7% of the women in the target population had one. This low number may be higher once private consultations are taken into account but that still only brings the number up to an estimated (they don't know for sure) 65% for France as a whole.

To be very clear, access to these prevention programs is not a question of money (direct payment). These "Dépistages organisés du cancer du sein" (breast cancer testing campaigns) led by the healthcare system and partners offer a complete mammogram to be read by two radiologists and a breast exam, all covered 100% by the national healthcare system with no co-payments or money up front. With a deal like that, one might assume that the participation rates would be much much higher (80-90%). But they aren't. Why?

Because "access" means much more than simply having care available and the means to pay the medical fees. The article I was reading cited several factors for the low breast cancer screening participation rates of which economic inequality was one (and here is where money does come into play). Like women all around the world, women in France have family and work responsibilities and the lower the socio-economic status the harder it is to manage them and to get an employer to give time off work. In more rural areas there is also the problem of getting to the nearest clinic or hospital which may mean a long drive or ride on the public transportation. As this article from late 2011 points out, a troubled economy makes it all so much worse: "À Paris, comme ailleurs, les inégalités sociales face à la maladie sont croissantes : de plus en plus de femmes repoussent les soins pour des raisons financières." (In Paris as elsewhere social inequalities in the face of illness are rising: more and more women are putting off care due to financial reasons.)

France is a country, however, where social solidarity means something. The annual campaigns to convince women to come in for screening are well-organized, well-funded and you don't hear anyone quibbling over the price tag. The French healthcare community is well aware of the low participation rates and is working on creative solutions to fix it: television, Facebook and even organizing teams to go out to neighborhoods and public places to talk to women directly. Another problem not much discussed in France is illiteracy which means that printed texts like pamphlets, posters and banners don't necessarily do much good in some places. (And if this sounds strange you, I can assure you that I have indeed met French women who are functionally illiterate and who would most assuredly NOT be able to pass a basic French reading/writing exam if they had to take one.)

There is also the very ambitious Plan Cancer which was started under President Jacques Chirac and was renewed for the period 2009-2013. Fascinating reading. The latest plan is organized around 6 measures "phares":

Produire et communiquer des informations sur le cancer et sur la cancérologie. (Produce and communicate information about cancer and oncology - I have a wonderful book the hospital gave me about chemotherapy that was part of this effort.)

Lutter contre les inégalités d'accès et de recours aux dépistages. (Fight the inequalities that limit access and participation in screening - see measure 14 here for the actions the state is taking to achieve this)

Développer une prise en charge sociale personnalisée et accompagner l'après cancer. (Develop a social support structure for cancer patients and for the life after cancer.)

It's a work in progress but you can actually see the results of this work in the hospitals and clinics here. At the end of the plan's period there will be a test - a national report card that rates how well these objectives were achieved and outlines areas for future progress.

I suspect that they will do very well indeed. The French may work less than people in other countries but, damn, they do know how to get things done and their ability to organize projects at a national level is almost frighteningly efficient. I could not be in better hands and I am deeply grateful to be here and not elsewhere.

Monday, September 3, 2012

We had some very sad news late last week - Andy Sundberg, one of the founders of American Citizens Abroad died in Geneva, Switzerland.

Mr. Sundberg was quite an amazing man and one of the most eloquent and influential voices defending the interests of Americans abroad. He was born in the U.S. but was also a French citizen and had lived in Europe since 1968. I did not know him personally but we had an email exchange a few months ago which greatly raised my spirits at a time when I needed some encouragement to remain active in the issues facing America's unloved "domestic abroad."

This article from GenevaLunch gives an excellent synopsis of his life and career:

Sundberg was born in New Jersey in 1941, finished grammar school in Japan, high school in Germany and he graduated from the US Naval Academy in 1962. The following year he was a Rhodes Scholar at Oxford University in England, taking a degree in Politics, philosophy and Economics. From there he went on to serve on combat ships near Cuba during the Cuban Quarantine and in the Gulf of Tonkin during the Vietnam war.He moved to Geneva in 1968, a time when he began to work as a consultant for major corporations, international organizations and governments, helping them evaluate investments and other key business areas.He was a life member of the Veterans of Foreign Wars, the American Legion, a member of the board of the Millennium Institute in Washington and the Key Largo, Florida-based Marine Resources Development Foundation...He became a French citizen thanks to his French wife, keeping dual nationality until his death. He was active in world and European politics, notably as a member of Liberal International since 1984 and as a participant in meetings of the Committee on Migration of the Parliamentary Assembly of the Council of Europe.

Andy's acheivements are so numerous, they take pages to list - but in all his activities there is a common thread, a unifying theme. He was dedicated to serving others, to serving causes that mattered deeply to him. As citizens overseas, we have benefited from the care, concern and dedication of Andy's energy toward the causes that few dared to take on - the causes of our overseas community, so often unrecognized and mischaracterized. He never waivered in his efforts to garner better recognition to what our community does for our American cause as a whole.

And finally the Isaac Brock Society has a post with their own tribute and links in the comments section to some very well-researched articles that Mr. Sundberg wrote over the years.

As Americans abroad face an uncertain future, Mr. Sundberg's voice will be sorely missed. It's up to us now to continue his work.

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Born in Seattle, USA. Generation Xer. Lived on 3 continents (North America, Asia and Europe). Country agnostic. Mother of two Frenchlings. Cancer survivor (so far). I believe in assignments, not jobs. I believe in networks, not companies. Passionate about technology, culture, language.